Wednesday, November 20, 2013

Note: There are - and will be - several subsequent posts to this that lay out the position of LightingEurope (representing Philips, Osram etc manufacturers) and other interested parties. See the blog homepage for latest posts.
LightingEurope has come out for the abolishment of stage 6 to keep allowing Halogens - and is also critical of the Commission suggestions to abolish special Halogen G9 and R7s types, and to enforce LED compatibility of fixtures - more of which below, which now include the Lighting Europe position statements. The LightingEurope position is otherwise covered in a specific post.

This post is based on the Commission proposal from the 21st of October, to delay general service Halogen incandescent lamp phase-out by 2 years, part of an ongoing Commission review of EU light bulb regulations on general service lighting that began 2009 - more on the overall review below.

For a comprehensive rundown why the regulations don't make sense as a whole:How Regulations are Wrongly Justified
14 points, referenced:
Includes why the overall society savings aren't there, and even if they were, why alternative policies are better, including alternative policies that target light bulbs.

The stated problem in the current Commission proposal is that while "B" class Halogen type replacements are technically possible they have not been found suitable (=profitable) enough to manufacture on any large scale. It is envisaged that the 2 year delay will, with plenty of public subsidies, therefore allow Philips, Osram, GE & Co to make LED products that will substitute for the 2 other major lighting types on today's market.

Thereby the envisaged end not just for incandescent lighting (simple or halogen type) but also for fluorescent lighting.
Fluorescents (CFLs) are conspicuously ignored in the paper and likely to come under increasing phase-out pressure, either from the removal of its current mercury content exemption, similar to already banned mercury containing thermometers, barometers and other products, or from a further reduction in allowable mercury, which effectively does the same (some mercury-free alternatives have appeared but not done well on the market, and further investment by major companies seems unlikely, as also per their industry response here, eg Lighting Europe).

The EU Review Process:
This is just the first part of the lighting ban review, dealing with "stage 6" i.e. general service Halogen specification.
The proposals will be discussed along with alternative suggestions on November 25 at a meeting in Brussels, open to "stakeholder" and other representatives from EU member nations, details below.
The overall review of the 2009-2014 ban will supposedly take place early next year in line with the 5 year review obligation as originally stated in passing the legislation, and ahead of a final consultation forum in April 2014.

However, updating this, some doubt seems to have been cast that further 2014 meetings will take place - it might just be left with this stage 6 review, in addressing light bulb availability.

Unfortunately the EU does not have great form in that regard, where the original regulation proposal never made it to the floor of the Parliament or to the accompanying media and public debate that might have taken place, debate (as it was) being cut short at the committee stage (How the EU regulated against incandescents, http://ceolas.net/#euban).
So those seeking to comment should not neglect to do it on that account.

UK submissions: Efficient.Products@defra.gsi.gov.uk
(DEFRA energy efficiency unit, EfficientProducts@defra.gsi.gov.uk also used)
Similarly to other EU national energy efficiency units of energy or environmental agencies, several of which can be seen listed at the end of the Consultancy Report linked below, together with the names of representatives.

EU Commission Suggestion 21-10-2013 amending Stage 6 of EC 244/2009EU Commission Regulation 18-3-2009 EC244/2009 (original), alternatively copy here
VHK/VITO consultancy research report overseen by Rene Kemna, underlying the Commission recommendations.
The latter, in the Annex, includes Minutes of the last Stakeholder meeting on the review of Stage 6 Requirements, held Friday 26 April 2013, Berlaymont building, Brussels. The list of attendants is attached at the end of the document. Many will presumably also form part of the November 25 meeting, in the same building (November 25 draft agenda, no details, 10.00-17.00)

The Commission technical report underlying the phase-out of incandescent lighting, analysis of replacement lighting, and - at the end - the timetable of phase out dates and requirements September 2009 - September 2016 EU technical briefing on lighting phase-out and dates

Implementing measures shall meet all the following criteria:
(a) there shall be no significant negative impact on the functionality of the product, from the perspective of the user;
(b) health, safety and the environment shall not be adversely affected;
(c) there shall be no significant negative impact on consumers in particular as regards the affordability and the life cycle cost of the product;
(d) there shall be no significant negative impact on industry’s competitiveness;
(e) in principle, the setting of an ecodesign requirement shall not have the consequence of imposing proprietary technology on manufacturers; and
(f) no excessive administrative burden shall be imposed on manufacturers.

Recommended Changes to the Regulations

Following the outcome of the review process, the Commission proposes to begin the revision procedure with the aim of adopting amendments to Regulation 244/2009 and Regulation 1194/2012.

The recommended regulatory changes include:
1. changing the entry into force of the stage 6 requirements to 1 September 2018, allowing LED technology to mature further and reach an optimal time point in terms of monetary and energy savings;
2. removing the current loophole by extending the stage 6 requirements to halogen lamps with G9 and R7s socket;
3. and introducing a provision that luminaires sold after 1 September 2015 should be compatible with LED technology to prevent future obstacles to efficient lighting

Regarding the proposed delay on banning general service mains voltage halogens:

While the likely delay is welcome, it should be made a permanent exemption.
The already marginal society energy savings are still smaller. It would also have shown some magnanimity in terms of consumers and their lighting choices.

In any case, temporarily or permanently, the EU should allow frosted (non-clear) halogens, a petty ban without energy saving justification, on the basis, from the underlying EU memorandum, that people "who want non-clear lamps can buy CFLs and LEDs", ignoring all other aspects of why a particular form of lighting is chosen.
Frosted bulbs are, or were, the dominant form of incandescents desired by consumers, especially in Northern Europe (90% of pre-ban incandescent sales, Philips/Osram data).

In fact frosted lamps, apart from reducing glare, ironically may have slightly higher brightness = more energy efficient (depending on luminescence and thickness of coating).
As one of the consultants behind the EU research confirms in their report:

Paul van Tichelen replies that we have to make distinction between clear and frosted equivalent.
A clear lamp is always in the lower lumen output.
The lamps we found with above 800 lumen output were for frosted lamps (higher lumen output than clear lamps).

[Note: "(higher lumen output than clear lamps)" albeit emphasized, is the original quote, it is not a comment addition. Clear LED lamps as referred to more commonly have lower brightness than clear incandescents in comparison with their respective alternatives, but the point remains, and energy efficiency differences were as said never a ban motive]

Conversely: Any general ban of mains voltage halogens removes the last possibility of using clear transparent burning filament lamps, with their unique "sparkle" effect in lanterns, chandeliers etc, unlike clear LED clones.
ENEA Italy comment in the consultancy report adds CFLs

CFL-i are, by definition, nonclear lamps, so their use as a substitution for clear lamps is in principle wrong...
Diversification of the market offer is very important.

The Commission likes to justify its actions with respect to what other countries are doing, more about that here.
Perhaps it's just a co-incidence that Canada just watered down its proposed regulations, specifically stating that it is to allow Halogens, having delayed implementation by 2 years in the first place.
Moreover, USA and Australia and other comparable jurisdictions which do have the similar intention of phasing out Halogens, do not engage in the specific EU petty ban on frosted (non-clear) Halogen types.

Regarding "closing the loophole" of G9 and R7 socket lamps:

The technical review study reveals that the exception of certain halogen lamps with a G9 and R7s socket from stage 6 creates a loophole, which some manufacturers have already started exploiting with adapter-kits.
These adapter kits allow consumers to use G9 socket halogens with a wide range of other sockets and are already available today. Given the low price of these adapter kits, in conjunction with the small retail price of G9 halogen lamps, it is likely that this loophole could significantly undermine the success of the stage 6 requirements as a significant portion of consumers might choose the presumably 'cheaper' option while paying more through non-realised energy savings.

Yes, how terrible if people are allowed to use what lighting they want!

Lighting choice is not just about what is cheap or what saves money in usage (and even if it was, so what?).
Plenty of other expensive product alternatives are marketed and bought for specific advantages.
"Expensive to buy but cheap in the long run" advertising sells woollen clothes, washing up liquids, batteries... without manufacturers lobbying for bans on cheap alternatives.
All lighting types have advantages for different situations:
"Switch all your bulbs and save money" campaigns are like "Eat only bananas and save money" campaigns.

Little consideration of light quality and other factors that also influence personal choice - as is obvious from their document which focuses on energy and cost in relation to lighting and the types that can relevantly be made on the basis of metered electricity usage alone.

Also see answers to specific sections below.

Update: LightingEurope (the major industry stakeholder representing Philips, Osram etc) in their position statement (as also covered in Post 3 of this Light Bulb Review series) is firmly against any action against these halogen types:

LightingEurope does not identify a real loophole in the exception of certain halogen lamps with a G9 and R7s socket from stage 6, nor the assumption that this loophole could significantly undermine the success of the stage 6 requirements in terms of energy savings.
In the view of LightingEurope, the Commission working paper gives too much relevance to so-called adapter-kits for these types of lamp sockets and draws a picture as if these adapters are sold in high volumes. According to the market observations of the European lighting industry, there is only one manufacturer of these adapter-kits and the availability in retail, and subsequently the presence on the market, is limited.
The adapter together with a bulb costs between 8 and 11 Euros, making it a niche product for special applications. It would appear to be doubtful to base the argument of including G9 and R7s into the requirements of stage 6 on the evaluation of a small market segment.
In addition to the huge negative impact which would arise if G9 and R7s socket halogen lamps would not be on the market anymore, no replacement would be available to consumers.

Regarding future compatibility with LED technology:

Some luminaires currently on sale are not compatible with future solid-state technologies, creating a 'lock-in' effect to old technologies such as halogen lamps. This might happen through design options limiting the dimensions of possible replacement lamps too much, or through the inclusion of functional elements such as control gear not compatible with LEDs. This creates an unnecessary obstacle to efficiency improvements and a burden to consumers. It is therefore crucial for the wide-spread acceptance of LEDs – and the overall transition to energy efficient lighting – to guarantee that new luminaires are ready for the future.

Notice the overall big emphasis of LEDs throughout.
The CFL replacement scenario - so dominant in 2008/2009 decision making - is not "cool" anymore.

As always, LEDs have their advantages and disadvantages too, fully covered elsewhere here.
However, once again, the EU Commission show their determination to get rid of "loopholes" like lamp sizes and fitting dimensions and control gear not being LED compatible - again reducing choice, on all criteria bar supposed energy usage.

Update:
Again (see last section) the major industry stakeholder LightingEurope in their position statement, while acknowledging the Commission reasoning, ends up critical of the EU stance:

• LED is not the only efficient lighting technology and may not be suited to all applications (especially in the Tertiary sector).
• The development of LED lamps and modules is still very rapid and the availability of new/current products, even in 6 months’ time, is unknown. The format of new LED lamps and modules (even Zhaga) that will be
available in 2015 is unknown.
• The crossover of LED technology between the Domestic and Tertiary sectors means that even if the proposal is limited to just Domestic there would be an impact on Tertiary.
• Even if the proposal is limited to just retrofit lamps as covered by 244/2009, compatibility would need to be carefully defined as hidden issues such as thermal compatibility can negate any benefits and mean a LED product is not 100% compatible in all luminaires.
• The equivalence of compatible LED lamps need to be fully considered from an installation perspective e.g. LED tubes.
• A deadline of 1 September 2015 is very close in terms of product development cycles and meeting this deadline would be impossible in many cases.

Regarding the failure of manufacturers to make promised Halogens:

The technical review shows that it is possible to produce halogen lamps which would fulfil the minimum efficiency requirements of stage 6 (B-class). Indeed, B-class mains-voltage halogen lamps were previously introduced to the market, but disappeared shortly after due to alleged technical difficulties and high consumer prices. This left the market without any B-class mains-voltage non-directional halogen lamps.
The review indicates that the widespread (re-) appearance of B-class halogen lamps no longer seems likely to happen.
It is expected that manufacturers will not produce such lamps, because the necessary investments in new technology would not be economically feasible given the expected retail price of these halogens and the expected general market transition to LEDs.

The Commission says "alleged" :-)
Do they actually doubt the manufacturer stakeholders?
It's not too surprising if they do:
As some readers may know Philips, for example, promised spectacular Halogen bulb development (eg EcoClassic) - before the ban. Hence stringent incandescent criteria implemented by the EU.
Ban achieved, job done, and the promise of greater fluorescent (CFL) sales.

Also regarding Philips Halogen B class bulbs...from the consultancy meeting following the report (annex of report):

Paul van Tichelen replies that when he looks on-line he finds also some old webpages of the Philips lamps, but they are not produced anymore.
Kees van Meerten (Philips) can confirm that the lamp is already three years not in production anymore.

To some extent this has therefore come back to haunt the manufacturers - but only temporarily.
Now the new promise is of even more profitable LED sales, since fluorescent bulbs, conspicuously absent from any mention, will likely also become banned or at least "phased out" on the new EU mercury content regulation they were previously exempted from.
Of course, the regulations have still allowed interim profit making from the fluorescents, and the taxpayer subsidies relating to them.

Regarding LEDs as sole future lighting choice:

LED technology will likely be technically ready to replace halogen lamps in 2016. Currently, there are a number of limited functional deficiencies in LED colour rendering, or LED compatibility with dimmers and other lighting controls in existing installations. These can put consumer acceptance of LEDs as the sole replacement option for mains-voltage halogen lamps at risk. However, it is expected that technological development continues, removing these functional deficiencies while further increasing the energy efficiency potential and life time of LED lamps and reducing their costs.

"Expected" technological development?
Why not first make sure such development has occurred?
Having made one anticipatory mistake, the EU now proposes another.

They can hardly doubt that such LED development would occur with or without a Halogen ban, since they keep talking about "the expected general market transition to LEDs".
Significantly: "All stakeholders agree that abolishing the stage 6 requirements would postpone these job losses by a small number of years – it would not prevent them." "These job losses will happen in any case due to the market transition to LEDs."

The suppostion therefore is that LEDS will replace Halogens anyway without EU regulation, will replace incandescent bulbs, and will replace fluorescent (CFL) lighting; as seen, CFLs do not figure in Commission plans and current mercury content exemption of CFLs will likely expire.

Regarding the financing of LED development:

The Commission also provides financial support for research and technological development of efficient lighting solutions.
The development of solid-state lighting such as LEDs has been proactively influenced by Commission investments and research grants. The Commission's 2011 "Green Paper on Lighting the Future" highlighted research that was already receiving 135 million EUR of EU funding. The "Horizon 2020" will provide further investments to facilitate the development and uptake of LED technology in the EU.

Further financial instruments exist for cities to finance investments in sustainable and energy efficient infrastructure and products, including lighting, at local level.
Examples are the ELENA technical assistance facility12 and the European Energy Efficiency Fund (EEE-F)13. These instruments can be combined with 'Green Public Procurement', which allows authorities from Member States to concentrate public spending on efficient and environmentally friendly technologies.

The working paper then sets out a whole range of public funding support for LED production.
There is nothing wrong with this as such: It's good to see research support for any lighting development, and new products need help to come to market - "free markets" can't solve everything.

But the support for LEDs does not necessitate banning all the alternatives "to make way" for LEDs.
Yes, energy saving is good, but should relate to the overall picture of energy saving in society, and the many more appropriate ways to achieve it, including specifically in electricity generation, distribution and consumption: http://ceolas.net

Perhaps all this is foreseeable - I predicted this double whammy profit-making hand-over for manufacturers soon after original legislation (http://ceolas.net/#li1ax onwards). Note - appropriately - how Philips just a few days ago announced record profits from lighting division LED sales.

But Philips & Co should not be blamed for seeking profits - the issue is why profits keep being handed to them by EU officials.

Regarding "LEDs getting better, cheaper and more attractive":

Solid-state lighting such as LEDs and organic light emitting diodes (OLEDs) promises up to 20 times higher efficiency than the old incandescent light bulbs while offering over 25 times the product lifetime. With these advantages, it is expected that LEDs will soon dominate the market. Price levels in Europe are still high for LEDs. But they are falling and are expected to continue to do so (McKinsey14 forecasts price falls of 16% per year). The choice of an LED rather than a CFL currently pays for itself in 5 years. This is expected to decrease to 1.7 years by 2016 and half a year by 2020.
The arrival of LEDs and OLEDs [as light sheets rather than bulbs] continues to change the market.

Good - presumably people will want to buy LEDs then - without needing a ban to force such a choice.

Fervent pro-ban supporters rather shoot-themselves-in-the -foot on this one,
like the Danish Energy Agency in annex comments of consultancy report, urging a speedy ban on halogens:

During the last year, we have seen a worldwide 50 % price cut for LED lamps....the LED lamps have a much higher efficiency (energy class A or A+) and actually the prices have decreased remarkably... the predicted average efficacies 80 lm/W for 2017-20 and 100 lm/W for 2017-25 are all too low....
/ etc /

Then again - they could of course not urge a ban on the basis that LEDs weren't good enough!

Ergo.
A basic piece of logic for the legislators.
1. New bulbs are ever better, cheaper and more desirable
= Less reason to keep banning the old ones, little society savings, and they're still a choice for special use or need.
2. New bulbs are not great
= Again less reason to keep banning the old ones - obviously.

Most experts agree that LED (possibly OLED) is the designated future replacement for MV-HL technology, but at the moment there are a number of technical/functional aspects such as colour rendering, dimmability, etc. and –most importantly-- the LED price that are potential barriers for consumer acceptance. These barriers are expected to be lowered to an acceptable level somewhere in the future, but the timing of forcing MV LED retrofits upon consumers is important.

Ah yes, consumers have to be "forced" to buy great products!
We are too stupid to make those right choices by ourselves.
If we were not so stupid, no ban would be needed for us. Thank you, EU people.

As the report agrees, price is not the only reason people buy light bulbs - besides, there is nothing wrong with products being cheap, and you don't keep buying cheap products that don't perform satisfactorily at the price.
As said, plenty of other "expensive to buy but cheap in the long run" products exist in the shops, properly marketed by manufacturers - when they don't run crying to the Commission, looking for quickfix bans.

Note how valves (vacuum tubes) are like incandescent bulbs, and how light emitting diodes are like transistors.
Questions..
If the EU of today had operated in the 1950's, would they have banned the "energy guzzling" valves too?
Would they have celebrated their effort on behalf of stupid citizens and the "wrong" choices they might make?
Would they have denied the world the unforeseen future niche use of these products (special audio equipment, guitar amplifiers etc).?

Pro-ban supporters say manufacturers change standards all the time.
Certainly: Philips, Osram and Co who cry about their environmental sensibility could of course just have stopped making incandescents themselves (the reason they didn't: ceolas.net/#li1ax).
Market product progress does not require Commission bans, and does not ban out-of-favour products for all time or for new manufacturers.

Progress?
There is something odd about all the "progress" talk in the consultancy report:
Drooling over retrograde LED clones of incandescents in the report annex that are "only" 20x as expensive at $12 or so (subventions not included).
One day, lighting progress might be discussed in terms of actual lighting advantages - not just in terms of lighting energy use.

How are better products - and, yes, better energy saving products -actually made?
By increasing - not reducing - competition.
Energy saving products can still be helped to market - and the better priceworthy ones survive. Similarly if new manufacturers of incandescents were encouraged, then longer lasting incandescents also for domestic use could break the monopoly of the short lasting types by the market controlling major manufacturers (the Phoebus cartel involving Philips-Osram-GE fixed standard light bulb life at 1000 hours, penalizing those seeking to make longer lasting ones).

Well now Peter, there's a sacrilegious thought.
I hope you know your way out of the Berlaymont building.

Regarding environmental impact, related to energy and emissions:

The estimated environmental impact is in favour of keeping stage 6 in place compared to a scenario where such requirements will be lifted. Confirming the ban would yield annual electricity savings of approx. 9.4 TWh and related greenhouse gas saving of 3.4 MtCO2 equivalent by 2020. The accumulative savings up to 2025 are around 43.2 TWh in electricity consumption and 15.2 MtCO2 equivalent.

Nonetheless, keeping the current stage 6 rather than abolishing it is not the environmentally optimal solution. While predicting the make-up of the future lighting market is prone to uncertainty, the review showed that deferring the coming into force of stage 6 is on balance the best option. LED technology will still benefit from efficiency improvements after 1 September 2016. LEDs purchased in 2016 will not be replaced with more efficient ones for years to come due to their long life-time, slightly diminishing the overall savings potential of the LED technology. The environmentally optimal solution is thus a (limited) postponement of the stage 6 requirements.

The Commission proposal leaves out some of what the underlying consultancy report says...yes, the immediate savings are supposedly there from immediate ban or 2-year delay.
But the fact that LEDs have a long lifespan and continually becoming more energy efficient is held to mean that purchases after 2018 are likely to lock in still more energy efficiency and hence greater savings.

The consultancy report (their "less/negligible" emphasis in bold letters in the original text, not mine):

Over a longer period till 2060 (see economics section), the LED ‘lock in’ effect (long product life prohibits application of more efficient LEDs or OLEDs), the difference becomes less/negligible and it may even be in favour of the abolishing Stage 6 from the environmental point of view.

The "2060" date might surprise some:
But if LEDs are going to last 40-50 years (see the consumer use assessment data below), one is supposedly talking about 2058-68 before changing bulbs post 2018.
"Invest in an expensive LED for your grandchildren!"
Which ignores all the reasons one might prefer shorter lasting cheaper (dare I say incandescent) bulbs for less used lamps, or bulbs for temporary accommodation, or indeed bulbs for anyone aged over 30-40 in permanent accommodation.

As covered under Consumer Savings, below, there are several other reasons why more frequent bulb switching may occur, also in switching from old LEDs to newer LEDs, which after all supposedly become cheaper and more energy saving all the time, and are expected to become voluntarily preferable to Halogens (questioning the ban rationale in the first place).

Notice therefore:
Since all seem to agree that LEDs will continually become more energy efficient,
then whether or not there is a lock-in effect, stage 6 should be abandoned:
1. Lock in effect is there
= early bad stage 6 LEDs 2016 locked into 40 year use
2. Lock in effect is not there
= continually replaced LEDs means ever more energy efficient LEDs are put in place.

That's just the start of it.
The 2020 CO2 emission savings data uses EU Impact assessment data from 2009, as quoted in the consultancy report - and the data was old even in 2009 (I saw the original EU memorandum) yet it is still as seen dug out and projected far into the future for big easily quotable supposed savings:
Ignoring EU 2020 emission reduction initiatives and further 2030-2050 measures in the same vein.

The same applies to mercury emissions: The use again of old emission data projected to 2020-2030, still stating "coal plant mercury emissions from incandescent use are worse than CFL related mercury", ignoring the accord negotiations promoted by the EU with UNEP, finalised earlier this year (Brussels, 19 January 2013, Commission welcomes new global agreement to tackle mercury, here).
The mercury saving supposition did not apply anyway, again for many reasons).
The EU like the USA loves this kind of spin of dubious projections far in to the future to achieve catchy big numbers for gullible journalists and politicians to swoon by...

There are 2 ways of looking at the energy savings data.
One way is the above way - quoting huge figures to impress everybody.
The other way is to put those figures into context.
As from US Dept of Energy and EU institutional data, about 1% of grid electricity and a fraction of 1% of overall energy use is saved (further covered in the points rundown energy section)
Certainly: Still substantial in megawatt terms, but it therefore raises the perspective of relevance compared to all other ways of dealing with generation, distribution and society consumption, as extensively covered on the ceolas.net site.

The temptation is to say "Well every little helps".
Ignoring issues of consumer choice and that all lighting has different usage advantages,
that is questionable even on energy savings grounds - both in direct usage, and in overall life cycle terms.

When are incandescent lights actually used?
Mostly after 7pm (DEFRA, Intertek referenced), off-peak in generation terms - which is why electricity is cheaper - no reason to deny Johnny use of whatever bulb he wants on energy availability grounds (and 5-7pm peak period lighting is a miniscule fraction of use, heating, cooking etc coming on, and added peak generation is usually low emission gas or hydro anyway).

Perhaps an EU official could take 5 minutes to make a phone coal to their nearest coal power plant, and how they work?Coal plants are "base loading", a permanent background source of electricity (unlike say wind power, without specific storage, which loses energy in back-to-forth conversion and so is not usually done).
Turning coal plants down and up has several maintenance cost issues, and while newer plants accommodate greater cycling, the operatively justified base load night cycle levels more than cover any consumer electricity demand at such times - which is also a reason electricity is so cheap then, on time-based pricing.
Lowering coal plant levels "to account for incandescent savings" (already small in grid demand percentage terms) is not an option given that operative levels are based on cost and wear and tear and slow stoking up to daytime use (see government and institutional references about this, as per above linked energy section). And that is even without looking at old Polish and similar coal plant operation.This alone questions the whole energy-emission saving argumentation behind EU light bulb regulations.
So it's not just about sticking 2 bulbs beside one another on metered comparison and assuming power plant savings are equivalent!

But that is still not all.
No consideration is given in report or proposal to incandescent heat replacement benefit (Finnish, Canadian, UK, German studies (http://ceolas.net/#li6x) to CFL/LED power factor issues effectively using more energy on phase differential grounds (same site, or the energy sections of the regulation criticism page on the left here).

There is also the issue of reactive consumer activity:

1. Compensation
Arguably the biggest issue is dimness - 100W incandescent equivalent omnidirectional brightness is difficult with both fluorescents and LEDs (thus the irony of early 100W bulb bans).
On the one hand, using legal halogens slows any supposed savings of conversion to LEDs.
On the other hand, using more fluorescents or LEDs per lit area (with less lumen output per bulb) also negates the supposed energy savings.

2. Rebound
If a product effectively becomes cheaper to use, it will tend to be used more, a well-known "rebound" effect in energy efficiency circles.
There is no EU study I know about this, but as referenced on the Ceolas site, the town of Traer, Iowa, USA had consumption monitored in a switchover program of incandescent bulbs for free fluorescents. Electricity use increased by nearly 10 percent. Because running the new lighting was cheaper, the inhabitants apparently felt they may as well keep them on longer.
Fluorescent lighting may be slow to come on in the cold and is supposed to be left on anyway to increase lifespan, factors also influencing leaving them on and increasing usage.
Leaving light on may be seen to influence public and commercial activities more than domestic users:
Public and office buildings left lit all the time, albeit for security reasons and the maintenance cost of more frequently changing fluorescent lights that are switched on and off.

Chasing down Johnny and what light bulb he wants to use somehow seems even more absurd.

Then there are all the life cycle factors,
raising the whole issue of environmental sustainability:

With:
Complex rare earth mineral depleting patented CFL/LED alternatives that are less easily locally made and involve more mining, component manufacture, product assembly, and recycling when not dumped (referenced US analysis below recommending recycling also of LEDs, on toxicity grounds).
In particular, all the extra transport use of energy and emissions in each of the above stages, including dirty bunker oil fueled ships bringing products or their parts from China.
In addition, an electricity usage that not only as mentioned is small and largely off-peak and therefore electricity that is available anyway - but also which, if emission-free, may actually lead to an increase in emissions with replacement bulbs and room heating from oil or other potentially pollutant sources, as referenced with different research studies.

Note:
The traditional analyst response to light bulb life cycle issues is to say
"Well, Osram says X energy is used in making those bulbs, and that is insignificant compared to usage savings!"
Certainly:
But that is therefore just the final assembly into a bulb - ignoring all the mining, component manufacture, recycling and certainly all the life cycle transport from raw material to component to product to recycling.
These are ignored (as are heat benefit, power factor and other effects) as being hard to quantify.
But estimates can be made about them - at least they should be taken into overall consideration.

Energy used in (say) China may be irrelevant to EU savings, but not released emissions on EU climate policy.
The proposal to support EU LED industry then raises the energy life cycle factors as well.

There is no excuse to leave out such factors in overall assessment.

Regarding environmental impact, related to health:

The review study examined the available knowledge on the impact of artificial lighting on human health from scientific publications. The update on health aspects did not identify any significant negative or positive impacts from the stage 6 requirements, or from a possible ban of halogen technology, due to the availability of suitable replacement options and the inclusion of certain information requirements in EU legislation.

Stage 6 requirements effectively only allow fluorescent or LED lighting for general service household lamps.

The issues with flourescent (CFL) bulbs are well known with respect to mercury, UV radiation, light quality and other issues - and also recognized as such by health and environmental agencies, for example in clean up mandates of bulbs and in recommendations of minimal distances and/or doubly enclosed CFLs for close usage.
A particular concern is the dumping of CFLs rather than going to recycling, with the associated risks of released mercury, as highlighted in a Swedish scandal in recent years - and Sweden tends to be seen as an environmentally conscious country, similar problems are not necessarily raised for attention elsewhere!
The concerns with CFLs are extensively covered and referenced here: http://ceolas.net/#li18eax

The new focus on LEDs may be assumed to diminish some of those issues.
But toxicity, resource depletion and environmental dumping concerns would nevertheless remain, as covered here in the safety section.
Department of Chemical Engineering and Materials Science, University of California, USA concerning the toxicity of LEDs:
"Higher resource depletion and toxicity potentials than the incandescent bulb due primarily to their high aluminum, copper, gold, lead, silver, and zinc.
According to California regulations, excessive levels of copper (up to 3892 mg/kg; limit: 2500), Pb (up to 8103 mg/kg; limit: 1000), nickel (up to 4797 mg/kg; limit: 2000), or silver (up to 721 mg/kg; limit: 500) render all except low-intensity yellow LEDs hazardous"
Because the bulbs have very different expected lifetimes, they “normalized” their data on resource depletion and toxicity potential by using data for fifty incandescents, five CFLs, and one LED bulb. Even after normalizing their calculations, the team found that CFLs have from three to 26 times higher resource depletion and toxicity potential than incandescents and LED bulbs have two to three times higher potential.
Figures are in reality higher still: incandescents can last much longer than the assumed 1000 hours, a standard arising out of the GE-Philips-Osram Phoebus cartel. LEDs 50 000 hour assumed life can similarly be questioned - it arises out of lab specifications rather than real life use, as covered here, and similarly with assuming CFLs to last 10x longer than standard incandescents.

But LEDs also have light quality concerns.
As it happens, the German Baubiologie association, on building construction, has in a recent 30th October article just warned against LED lighting on flicker grounds, not necessarily noticeable by the human eye, leading to people feeling unwell in the different ways described.

The official French health agency ANSES in 2013 again pointed out issues seemingly unadressed by the EU, relating to source glare and blue light issues, originally highlighted by them in extensive 2010 research.
Unforunately the problems particularly arise with the most common "white LED" lamp types.
Translated from the French research.. Necessary to restrict LED availability ahead of proof of not presenting a greater blue light danger than traditional forms of lighting do... necessary to adopt new norms (NF EN 62 471)... necessary to show respect for sensitive and particularly exposed individuals... necessary that norms are respected also generallly relative to comfort and visual conditions in workplaces and homes...
recommendation to reduce LED lighting usage particularly where there is glare from the luminaries used... recommendation for EU labelling to more clearly show light quality and photobiological risk according to norm NF EN 62 471
LED blue light has diverse health problems as easily seen by several other studies online.

CFLs and LEDs can hardly be made, and are rarely sold, to equivalent omnidirectional c.1380 lumen brightness of 100W incandescent bulbs, of particular issue to old people with worse eyesight.
But that is not all:
A particular issue of the greater blue light component of CFLs and LEDs is that this makes such lighting appear still dimmer to old people, since eye lenses yellow with age, absorbing such light.

The MV-HL lamp has 36W power (500 lm, 14 lm/W), 2000h product life and a list purchase price of € 3.
The equivalent LED lamp is expected to have 5.4 W power (500 lm, 93lm/W), 20 000 h product life and a list price of € 10.
Both are assumed to have an operating time of 500h per year and thus the MV-HL uses 18 kWh/year (€ 3.96/year in electricity at a 2016 electricity rate of € 0.22/kWh) and the LED lamp uses 2.7 kWh/year (€ 0.60/year at the same rate).

Using 2016 parameters and list prices, the expected ‘payback period’ of LED versus MV HL lamp is around 2.4 years at 500h/yr.
At an operating time of 250h per year, instead of 500h per year, the payback period would be 4.2 year

A criticism of these figures suitably has 3 sections, the data itself, other energy usage factors, and extraneous indirect factors affecting what consumers pay.

1. The data itself

Bulb Lifespan
Quoted as 2000 hrs for Halogen and 20 000 hrs for LEDs.
LED lifespans have several question marks in their lab based specifications (more - http://ceolas.net/#li15ledax), but 20 000hrs is more conservative than other common estimates by regulation supporters. As it happens it makes little difference in the overall savings perspective, as per the data: acquistion cost is a minor factor compared to running cost.

...the service life assumption of 40 years for LED is rather unlikely...
operating hours... switch-on times... cannot translate into service life without much ado.
Opposing facts (that are admittedly not easy to measure) are impacts such as premature scrapping e.g. for reasons of fashion, diminishing brightness, colour changes in light, more efficient successor products or the combination of the LED with other technical features (such as wireless control options integrated in the base).
The aging of structural components without operation (particularly organic compounds such as adhesives or parts of electronic systems) also speaks against a service life of 40 years.
Also, the standard plastic bulbs typically used display some marked decolouration (e.g. yellowing) after a few years in practical use, which can lead to premature replacement, too.

In that case, if people switch bulbs more often, and LED energy efficiency progresses as the Kemna report also suggests, then the usage savings keep increasing anyway, stage 6 or no stage 6 (see energy comment, lock-in effect, above).
A ban on halogens obviously leaves little choice, while if LEDs get better and cheaper people will buy more of them whatever the other choices are - which of course challenges the need to ban any incandescents, not just halogens.

Bulb Usage
The consultancy figures, while not assuming a high 3 hr daily average usage per bulb (1000 hrs per annum), still come out at a rather high -roughly- 1 1/2 hrs (500 hours p.a.) or 45 mins (250 hours p.a.) daily average usage assumption per bulb.
As seen, the Commission Proposal uses the higher 500 hour per year LED lamp usage assumption.
Previous Paolo Bertoldi et alia EU Commission surveys have shown 20-25 lighting points per EU household, substantially more in Northern Europe. Usage doubtfully comes out as such high figures per bought bulb. In fairness, the most used bulbs would likely be replaced first, so there would be an initial stacking of higher average use among those
bulbs, but this would therefore soon become progressively lower, as less used bulbs become replaced, particularly on assuming legacy incandescent short lifespan stock are fitted.

There is also an assumption based on extrapolating sales figure curves which does not necessarily hold.
Replacing commonly used bulbs with LEDs has a desirable payback logic for the consumer, but this decreases more and more for less used bulbs, and resistance to purchase (and using stocked bulbs, smuggled bulbs, allowable halogens) may be expected, unless LEDs hit the 3 euro kind of level assumed for halogens.
A second reason for increasing consumer resistance is that lighting situations that don't suit LEDs would increasingly come up eg dedicated dimmer, timer, sensor circuits, old fittings, etc, and in fairness the consultancy report mentions this, along with brightness requirements that in particular the cheap LEDs would hardly match, and the Colour Rendering Index (CRI) which is maximal 100 for incandescent lighting (Aside note: hence the clamour for a new Colour Quality Scale (CQS) index that, er, shows LEDs in a better light. Ah yes).

Of course if the EU simply invokes a final solution ban of all non-LED light bulb alternatives, the problem is largely, as it were, "solved"! Screw citizens, screw citizen choice.

Electricity Price
Average prices seem to have been used. Most lighting usage is off-peak after 7pm on DEFRA-Intertek UK data, likely similar throughout the EU based on work times and evening darkness. Time-based electricity pricing is becoming more common and is favoured by utilities. While currently consumer night-pricing often has relatively late start times, the expected smart grid-smart meter developments will likely radically alter this.
Since the EU savings are projected far into the future, they should take that into account.
Conversely "energy shocks" (Germany?) might raise prices, but hardly in equivalent fashion, and overall the future in terms of varied available energy sources for electricity is assured, even with lots of green fingered interference.

Overall
The consultancy report is a lot more reasonable than others I have seen in savings projections.
That said, in the 2025 perspective they use the savings are highly questionable - and predictably questionable right now, not just because 2025 is far away.
The Commission stance is even more questionable as based on the higher 500hr yearly average bulb usage assumption.

2. Energy usage factors

Previously mentioned factors affecting energy savings obviously also affect money savings.
Hence the mentioned incandescent heat benefit and the inferior CFL/LED power factors both lower supposed switchover savings, the latter also in any costly countermeasures that utility companies may have to take (which is why industrial users are cost penalised if presenting power factor disadvantages to the grid).

Also as mentioned, the consumer reactive activities - using more dim bulbs to compensate for the lack of omnidirectional bright ones, or preferring brighter halogens (with higher electricity usage per bulb) for the same reason.
Again, the rebound effect of leaving lights on that are cheap in usage, especially fluorescent types that are slow to come on in the cold and where on-off switching reduces lifespan.

3. Extraneous factors

Government subventions with taxpayer money should be taken into account for supposed consumer savings.
As seen under financing above, the EU proposal itself goes into a few of the subventions for light bulb manufacturers to make the bulbs - and for municipal governments and others to buy them.
That means consumers paying much more than what the price tag on the bulb says - without it being acknowledged.

But again, that is not all.
Power utilities are also subvented for expected lower sales and/or they are allowed to raise prices for expected lower electricity sales arising out of consumer energy efficiency measures such as on light bulbs, as seen in UK, Germany and likely elsewhere.

Regarding Local versus China Manufacture:

LED modules are mainly produced in Asia. On the other hand, the EU is the main manufacturer of halogen lamps.
LEDs are mainly produced in Asia by companies with experience in computer chip production, because their manufacturing requires chip wafer technology and expertise similar to that used in the silicone industry. Major producers are companies like Nichia, Samsung LED, LG Innotek and Seoul Semiconductor. While Osram Opto Semiconductors was the world's third biggest supplier of LED components in revenue terms in 2011, it mostly specialises in high value LED and SSL-Laser technology used in special applications such as surgical instruments. The absence of a strong chip industry in the EU is therefore one of the major obstacles to relocating general LED production to Europe.

Halogen lamp production is mainly EU-based with a share of 72% on the European market with 234 million unit sales in 2012. Employment dependent on the current production in the EU is estimated at a maximum of 7,300 industrial jobs. With the knowledge of today, the industrial activities linked to LED replacements - imported from outside the EU - are expected to bring 500 new EU jobs.
Hence, it is estimated that a maximum of 6,800 jobs related to halogen production will eventually be lost.

These job losses will happen in any case due to the market transition to LEDs.
All stakeholders agree that abolishing the stage 6 requirements would postpone these job losses by a small number of years – it would not prevent them.

Jobs are clearly an issue.
The EU already acknowledged loss of at least 5000 EU jobs in the initial 2009 shift from simple incandescents - and that was just in the final phase, as manufacturers had already begun to adjust for assumed (and promised) legislative changes.
Simple incandescents, which comparatively also includes Halogens, are easy to make locally by new and/or small start-ups:
Firstly, in needing few component resources to thereby efficiently (note, "efficiently") make bright lighting.
Secondly, as patent-expired, generic light products without licensing requirements.
Thirdly, in environmental authorization, not handling toxic minerals or having inappropriate waste products or being subject to recycling collection mandates, which as mentioned has some imperatives with LED products.

But also the mentioned environmental issues relating to manufacture locality, local or not local:

1. Manufacture in China
Aside from any loss of EU jobs, note the less environmental conditions of production processes from mining to coal plant powered manufacture to bunker oil fueled ships to Europe, and possible return of recycled reprocessed parts.

2. Local manufacture
In this case, politicians can no longer ignore the manufacture energy use - which goes beyond the commonly quoted Osram and similarly based data which while showing 6-10x differential for CFLs over incandescents (and as per consultancy report US Dept of Energy referenced study, much more for LED manufacture) still only relate to assembly of components, largely ignoring component manufacture and certainly the other life cycle energy and emission issues already mentioned.

These job losses will happen in any case due to the market transition to LEDs.
All stakeholders agree that abolishing the stage 6 requirements would postpone these job losses by a small number of years – it would not prevent them.

As seen this reiterates the expected market transition to LEDs.

Conclusion

So to suitably conclude, returning to the stage 6 issue raised in the proposal:

A. If as suggested the market transitions to LEDs anyway without the stage 6 requirements that ban Halogens, based on "LEDs are getting better and cheaper all the time":
Why then ban the Halogens. Presumably people buy more and more LEDs - voluntarily.
It can therefore hardly matter on any meaningful energy saving grounds, added to all the other stated referenced reasons that the savings are not there - and may for that matter give greater savings, as per point B.

B. Since all seem to agree that LEDs will also continually become more energy efficient, then whether or not there is a lock-in effect (from purchased long lifespan LEDs not getting changed), stage 6 can be abandoned also on those grounds:
1. Lock in effect is there
= early less energy efficient 2016 LEDs locked into 40 year use
2. Lock in effect is not there
= continually replaced LEDs means that ever more energy efficient LEDs are put in place.

C. In allowing Halogen lighting, there are no energy saving grounds for maintaining a ban on frosted, non-clear lamps.
Indeed, as from the research report, they are often more energy efficient than clear varieties, as well as having less point-source glare. The original ban argument that "people can buy CFLs/LEDs if they want non-clear lamps" obviously ignores all the other reasons why particular lighting is chosen.
No other jurisdiction than the EU maintains such a petty ban on non-clear lamps.

This is of course itself only a small part of why banning cheap popular safe electrical products makes no sense:
Unlike - say - usual cars, light bulbs are only indirectly related to the energy used and any associated emissions, and a predominant evening-night off-peak surplus supply use along with fractional grid demand negates any reasonable justification to ban a popular choice of artificial lighting, which people spend much of their lifetimes using.

If there is a problem - deal with the problem.

Footnote:
EU Commission = European Commission, official nomenclature.
I consider EU=Europe language as also reflected by "pro-Europe" etc usage as being a false equivalence (I am certainly pro-Europe, whatever about the EU).
Language use is an often ignored subject in influencing how people think (obviously freedom fighters v. terrorists and such politically, but environmentally also (constructional) efficiency v. (energy) efficiency, energy saving bulbs v. fluorescent bulbs, all-encompassing "climate change", CO2 pollution v. CO2 emissions etc) whether or not one agrees with the motivation for such use.